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TMI Blog2023 (8) TMI 1195X X X X Extracts X X X X X X X X Extracts X X X X ..... ch of this court in CIT v. Kabul Chawla [ 2015 (9) TMI 80 - DELHI HIGH COURT ] The decision in Kabul Chawla s case has been affirmed by the Supreme Court in Principal Commissioner of Income Tax v. Abhisar Buildwell, [ 2023 (4) TMI 1056 - SUPREME COURT ] Given the position that no incriminating material was found qua the AYs in issue, we find no reason to interfere with the impugned judgment. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e appeal. 3. Having regard to the period of delay, we are inclined to allow the prayer made in the application. 3.1 It is ordered accordingly. 4. The application is disposed of, in the aforesaid terms. ITA 419/2023 5. This appeal concerns Assessment Year (AY) 2009-10. 6. Via this appeal, the appellant/revenue seeks to assail the order dated 23.11.2022 passed by the Income Ta ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... impugned order: 20. As per the seized paper 34 of Annexure A-2 and page 37 of Annexure A-3 which are containing vouchers showing payment in cash for purchase of milk for AY 2010-11 2011-12 pertaining to the assessee. Admittedly the alleged documents were seized during the search are not pertaining to the assessment year 2007-08 to 2009-10 and the same is belongs to Assessment years 2010-11 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nlease Construction (P.) Ltd. [2019] 104 taxmann.com 295(Delhi-Trib.), PCIT Vs. Index Securities (P.) Ltd. [2017] 86 taxmann.com 84, CIT Vs. Kabul Chawla (380 ITR 573). Thus, it is clear that the satisfaction though recorded was not based on the material relevant to the year in question and also the additions made were not based on the incriminating material found and seized during the course o ..... X X X X Extracts X X X X X X X X Extracts X X X X
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